Classification and Labelling of Chemicals

If a risk assessment shows that a complete labelling is not necessary the labelling may be facilitated. This is only possible if there are operating instructions and if the staff has been instructed about the possible hazards at the workplace and the safety measures.

With a facilitated labelling the label must at least contain the name of the compound and the hazard pictograms (CLP-regulation) of the main risk(s) by

physical-chemical,

health hazardous or

environmental risks

of the compound.

If the resulting information of a facilitated labelling is too unspecific, it may be necessary to add a hazard code or other short descriptions.

Solution proposals are found in annex 4 of the BGI/GUV-I 850-0. Unfortunately labels described in this text at the moment are only available at the "Jedermann-Verlag" and are quite expensive. But if you print out CLAKS labels you will find there pictograms and warning phrases.

Labelling of unknown reaction products

Compounds - so far not classified or with unknown structures of course cannot be labelled with H- or P-phrases. Nevertheless according to Section 8 of the Hazardous-Substances Ordinance all these compounds must be identifiable. You may perform this by having a coding system and if you could check by the entries in your lab journal how these compounds have been prepared. This is also a good practice for the scientific aspects of your work.

Labelling of small quantities

For several less hazardous compounds a labelling is not necessary if the size of the bottle is not bigger than 125 ml. See details in the TRGS 200 and in the CLP-regulation. (Use the search engine of your pdf-reader to search for the string "125") Unfortunately the rules are very complicated.

For a classification of a compound it has first to be defined which hazard classes and, where applicable, which categories apply. From every category of a hazard class a H-phrase and a pictogram is derived. If all pictograms of all hazards are put together, the result may be confusing.

Example:

If the following pictograms are derived from a classification,

then the "exclamation mark" has no more warning effect besides the skull. According to article 26 of the CLP-regulation the "exclamation mark" therefore may be omitted. Further simplifications according to artikel 26:

Besides...

... may be omitted

and

for irritation of skin or eyes

for respiratory sensitation

for skin sensitation or for irritation of skin or eyes

Are there more than one classifications within a hazard class then only the pictogram of the most hazardous classification applies.

Example:

If in the hazard class "acute toxicity" there is a classification "toxic if swallowed" and a second classification "harmful in contact with skin" then only the skull-pictogram is used for the classification as "toxic".

As a rule the GHS-labelling system has to be implemented in every country separately. But for all countries which are members of the EU it is the EU-government which has implemented the GHS by the CLP-regulation ("Classification, labelling and packaging"). This regulation has a direct legal effect for all EU-countries. This means that all things concerning classification, labelling and packaging are regulated in all these countries in the same way.

As a rule it is the job of the manufacturers to classify their offered chemicals. A special feature of the clp-regulation is that in annex VI there are approximately 3000 compounds listed with their classification. This means that for these compounds the labelling is fixed and must be applicated in all EU-countries in the same way. This is called a "harmonised classification".

Online-conversion-tool of the BG-RCI, where old EU-labellings may be changed into a GHS-labelling. The accuracy of the conversion could be enhanced if data of the hazardous potential (for example flash point or LD50-values) are available.